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Controlled Act of Psychotherapy

Understanding the Controlled Act of Psychotherapy

The 14 controlled acts are inherently risky and should only be performed by a properly qualified professional to ensure client/patient safety. The controlled act of psychotherapy is one of these legally restricted acts.


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Controlled Act of Psychotherapy

Understanding the Controlled Act of Psychotherapy

The 14 controlled acts are inherently risky and should only be performed by a properly qualified professional to ensure client/patient safety. The controlled act of psychotherapy is one of these legally restricted acts.

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The Controlled Act Explained

 

The Regulated Health Professions Act, 1991 sets out 14 controlled acts that are inherently risky and should only be performed by a properly qualified professional to ensure client/patient safety. The controlled act of psychotherapy is one of these legally restricted acts.

 

It is defined as:

 

Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgement, insight, behaviour, communication or social functioning.

 

The controlled act applies to practitioners physically present in Ontario, and those located outside of Ontario who are providing services to clients in Ontario (example: via video call).

Controlled Act of Psychotherapy

Modalities of Psychotherapy

The following are examples of therapy modalities that fall under the five categories of psychotherapy. These examples are not intended to be exhaustive, rather they are intended to help RPs situate their own practices within what are intended to be broad categories.

Cognitive and Behavioural Therapies

  • Acceptance and Commitment Therapy
  • Cognitive Behaviour Therapy
  • Dialectical Behaviour Therapy
  • Exposure Therapy
  • Mindfulness Based Cognitive Therapy
  • Rational-Emotive Therapy
  • Schema Therapy

Experiential and Humanistic Therapies

  • Art Therapy
  • Emotion-Focused / Emotionally-Focused Therapy
  • Gestalt Therapy
  • Multicultural Therapy
  • Music Therapy
  • Play Therapy
  • Psychodrama
  • Rogerian Person Centered Therapy
  • Spiritually Integrated Psychotherapy
  • Satir Transformational Systemic Therapy
  • Sex Therapy

Somatic Therapies

  • Biofeedback
  • Ericksonian Hypnosis
  • Emotional Freedom Therapy
  • Eye Movement Desensitization Reprocessing
  • Neuro Linguistic Programing
  • Sensory Motor Therapy
  • Somatic Experiencing

Psychodynamic Therapies

  • Adlerian Therapy
  • Existential Therapy
  • Psychoanalytic Psychotherapy
  • Interpersonal Psychotherapy
  • Jungian Analysis
  • Object Relations Psychotherapy
  • Reichian Therapy
  • Relational Psychotherapy

Systemic and Collaborative Therapies

  • Dialogic Therapy
  • Family Systems Theory
  • Multisystemic Therapy
  • Narrative Therapy
  • Solution Focused Therapy
  • Strategic and Structural Therapies
Controlled Act

Activities Outside the Controlled Act

  • Activities Outside the Controlled Act

    CRPO has developed a list of activities that are deemed to be outside the controlled act of psychotherapy. Registered Psychotherapists may do some of these activities as an ancillary activity within the scope of their psychotherapy practices, but providing only the services below would not constitute the controlled act. These activities include but are not limited to the examples listed below.

Controlled Act

Activities Outside the Controlled Act:

  • Examples

    • Advocating
    • Applied Behavioural Analysis
    • Case management
    • Clinical follow-up/care and discharge planning
    • Parental coordination
    • Counseling and support, including advising/advice-giving, instruction, assisting in resolution of dilemmas, assisting in improvement of coping strategies
    • Crisis intervention/management, including de-escalation, safety planning, referral to other services

  • Examples Continued

    • Hypnotherapy, including smoking cessation
    • Information/advice and knowledge transfer
    • Intake and referral
    • Mediating
    • Milieu therapy/milieu-based interventions
    • Monitoring
    • Problem solving, including information and advice giving, 12 step program, social skill development, instruction, emotional regulation

  • Examples Continued

    • Psychometric testing or assessment
    • Rehabilitation, including helping an individual to deal with the physical symptoms of a medical illness, resuming activities of daily life, learning or relearning skills that assist in carrying out the activities of daily life
    • Single session counseling
    • Spiritual or faith guidance/counseling
    • Teaching, including social skill development, emotion regulation, prescriptive programs

Controlled Act FAQ: Practising Prior to Registration

Unregulated providers performing the controlled act of psychotherapy will need either to restrict their practice or register with CRPO or one of the five other colleges whose registrants can practice psychotherapy*. Complete our Self-Assessment Tool to help determine if you are performing the controlled act.

 

There are limited exceptions or exemptions that allow an unregulated provider to perform a controlled act. These include treating someone by spiritual means according to the tenets of the religion of the person providing the treatment, Indigenous persons providing Indigenous healing to other Indigenous persons or members of an Indigenous community or acting in an emergency. There is also an exemption for individuals fulfilling the requirements to join the profession (e.g., students).

 

If an unregulated individual performs the controlled act, CRPO could investigate, take legal action, and publish information about the individual on CRPO’s website. Regulated providers may be investigated by their own college if they do not perform a controlled act in accordance with professional standards.

Individuals who are training to become Registered Psychotherapists will need to have an RP supervisor in order to perform the controlled act of psychotherapy, e.g. during practicum. CRPO is aware that many education and training programs have interprofessional faculties and that clinical supervision in placements provided by these programs might involve supervision by other professionals. While the Regulated Health Professions Act, 1991 requires that those intending to register as RPs receive clinical supervision of the controlled act from only RPs, there is no reason that students cannot also receive supervision from other professionals for the broader scope of practice. Learn more on our Clinical Supervision Information section.

 

Students are strongly encouraged to apply for registration once they have substantially completed their psychotherapy program. If they do not register once they are eligible to do so, they will no longer be permitted to perform the controlled act of psychotherapy.

Students should discuss their role and responsibilities with the placement site clinical supervisor to determine if they will be performing the controlled act.

You will need to find an external RP clinical supervisor or find another placement site. Alternatively, you could discuss restricting your practice at the site to not involve performing the controlled act.

CRPO does not specify the number of clinical supervision hours required from the RP. How much clinical supervision with the RP will depend on how often the student is performing the controlled act. Students should discuss this with their clinical supervisors.

If an RP (Qualifying) registrant is expanding their area of competence to involve the controlled act, they must seek clinical supervision specific to performing the controlled act. More information can be found in the Professional Practice Standards in Standard 2.1: Seeking Consultation, Clinical Supervision and Referral.

Yes. As of January 1, 2020, individuals fulfilling the registration requirements to join CRPO are permitted to perform the controlled act of psychotherapy under the supervision of a Registered Psychotherapist.

Assuming the courses are geared toward fulfilling CRPO’s education requirements, and assuming the supervised practise is completed as part of taking those courses, then yes, an individual would be authorized to perform the controlled act of psychotherapy to fulfill the remaining registration requirements.

No. Once you have fulfilled the minimum requirements for registration (e.g. completing an education program), you need to register with CRPO for authorization to perform the controlled act of psychotherapy.

No. Unregulated practitioners are not permitted to perform the controlled act of psychotherapy unless an exception or exemption applies. One exception applies to individuals fulfilling the registration requirements for joining CRPO. It does not apply to anyone practising under the supervision of a Registered Psychotherapist.

There is no clinical experience required to register with CRPO in the RP (Qualifying) category.

None. CRPO will only assess whether the 450 direct client contact and 100 clinical supervision hours fall within the broader scope of practice of psychotherapy. More information about the requirements to transfer to the RP category can be found here.

No. Applying for registration does not authorize an individual to perform the controlled act of psychotherapy. We encourage students to submit their application as early as they can to avoid a gap between completing their education and receiving registration with CRPO.

No. Appealing a CRPO registration decision does not authorize an individual to perform the controlled act of psychotherapy.

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